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<p>Tax Bulletin www.pwc.com/sg Singapore Common Reporting Standard (CRS) – Guidance on registration requirements On 18 August 2017, the Inland Revenue Authority of Singapore (IRAS) released Common Reporting Standard (CRS) registration guidance and FAQs, providing clarity on registration procedures with the IRAS, including the usage of IRAS EASY Authorisation System for reporting purposes. Reporting Singapore Financial Institutions (SGFIs) have the responsibility to collect and report CRS information of its account holders. Part of the compliance procedures involve registering with the IRAS. Please refer to our tax bulletin in April and August 2017 for key CRS regulatory changes and updates to the IRAS FAQs respectively. The following summary provides a brief overview of how these registration procedures may affect you and your business. Objective of CRS The CRS is an internationally agreed standard for the automatic exchange of financial account information (AEOI), to detect and deter tax evasion by taxpayers through the use of offshore bank accounts. Financial Institutions will have to report specified account information of their non-Singaporean tax resident account holders to the IRAS. The Singapore CRS registration requirements All SGFIs are required to apply for CRS registration. An entity that becomes a Reporting SGFI at any time during a calendar year must submit an application to register with IRAS by 31 March of the following year, i.e. an entity that becomes a Reporting SGFI between 1 January 2017 and 31 December 2017 (both dates inclusive) must submit an application to register with the IRAS by 31 March 2018. However, the above requirements do not apply to Reporting SGFI which is: a) point (a) an investment entity that only carries out specified activities* as an investment entity for and on behalf of customers for the purpose of investing, managing or administering financial assets deposited in the names of those customers with another financial institution. b) an entity (non-trust) which is resident in Singapore and other Participating Jurisdiction(s), of which its CRS reporting and due diligence are carried out in the other Participating Jurisdiction(s) where the financial accounts are maintained or the branch is located, and does not have any financial accounts in Singapore nor a branch located in Singapore. c) a trust which is resident for CRS purpose in Singapore and other Participating Jurisdiction(s), where its Reportable Accounts information is reported in that other Participating Jurisdiction(s) in which the trust is a resident for tax purposes, and each Trustee (including the Singapore resident trustee) is able to demonstrate that all necessary reporting in that other Participating Jurisdiction(s) by the trust takes place. PwC Singapore Tax Bulletin – Common Reporting Standard (CRS) August 2017 d) a Trustee-Documented Trust, which its trustee is a Reporting SGFI and undertakes the due diligence and reporting obligations of the trust. * Please refer to the IRAS CRS Registration FAQs for more information. Commentary: Singapore financial institutions should assess whether they come within the definition of a Reporting SGFI and review whether any of the exceptions apply prior to registering for reporting with the IRAS. Notwithstanding the registration deadline for reporting year 2017 is 31 March 2018, Reporting SGFIs are required to comply with the CRS regulations including the due diligence procedures as part of the CRS requirements under Singapore law. Submitting an application for CRS registration From 31 August 2017, Reporting SGFIs can submit an application for CRS registration. It is expected that the application for CRS registration will take about three weeks to be processed, after which the Point of Contact (POC) or individual trustee will be informed of the outcome. The following information is required for CRS registration: Reporting SGFI, other than a Trust 1. Singapore tax reference number of the Reporting SGFI 2. Singapore tax reference number or passport number of a POC for the Reporting SGFI 3. Letter of Authorisation (LA) for the POC, which is to be signed by Reporting SGFI’s director or principal officer authorising an individual as the POC for CRS Reporting SGFI which is a Trust 1. Singapore Tax Reference Number of the Trust, if available 2. Trust Deed, or an Agreement that evidence the creation of the trust is require if the Trust does not have a Singapore Tax Reference Number 3. Singapore Tax Reference Number of the trustee 4. LA for the trustee’s POC (for non-individual trustee) Commentary: The application is expected to be processed online through the usage of the IRAS tax portal. Notably, registration will be done via the use of the Singapore Tax Reference Number. For non- individual entities, the Singapore Tax Reference Number refers to the Unique Entity Number (UEN), Income Tax Reference Number (ITR) and IRAS Assigned Tax Reference Number (ASGD). FATCA information for CRS registration The IRAS intends to use the same system to collect both CRS and Foreign Account Tax Compliance Act (FATCA) information from Reporting SGFIs in future. As such, the IRAS is capturing the FI’s FATCA registration information at the time of the CRS registration as well. Commentary: Impacted SGFIs should take the opportunity prior to registration to ensure compliance of their CRS and FATCA obligations and assess readiness for CRS and FATCA reporting. Authorisation of Third Parties for AEOI e-Services Unlike FATCA, CRS does not have the concept of sponsoring and sponsored entities. For a company which undertakes the CRS reporting on behalf of a Reporting SGFI, it will have to be authorised by the Reporting SGFI via the IRAS EASY Authorisation System (and, in future, the CorpPass System) as a Third Party in order to access the AEOI e-services and transact with the IRAS on the Reporting SGFI’s behalf. Commentary: Used for other tax services, the extension of the EASY Authorisation System to CRS reporting eases the burden of Reporting SGFI to conduct reporting on its own. Reporting SGFIs unfamiliar with the CRS XML Schema will be able to rely on external service providers for its reporting via the IRAS EASY Authorisation System. CRS Reporting SGFIs will be required to report their CRS Return in XML Schema. The IRAS had issued the draft CRS Return XML Scheme User Guide for public consultation in June 2017. The final guidelines have yet to be released. Please refer to the draft IRAS CRS Return XML Schema User Guide for more details. Commentary: Businesses may assess their current state readiness of system facilitating information extraction for CRS reporting using the draft user guide. Please refer to the IRAS CRS webpage for the full details of the release. Your PwC contacts If you require further assistance in respect of CRS matters, please reach out to our PwC FATCA and CRS team. Brendan Egan CRS and FATCA Tax Leader T: 6236 3928 M: 9821 7300 E: brendan.m.egan@sg.pwc.com Denise Lim CRS and FATCA Process Implementation Leader T: 6236 4208 M: 8127 3801 E: denise.ll.lim@sg.pwc.com This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers Singapore Pte Ltd, its members, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it. © 2017 PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details. </p>
